*'AR U.S. ENVIRONMENTAL PROTECTION AGENCYOffice of Pesticide Programs

Antimicrobials Division (751 OP)1200 Pennsylvania Avenue NW

Washington, D.C. 20460

NOTICE OF PESTICIDE:x Registration

Reregistration(under FIFRA, as amended)

EPA Reg. Number:

73139-3

Date of Issuance:

282014

Term of Issuance:

Conditional

Name of Pesticide Product:

DIKLOR G ChlorineDioxide SterilantPrecursor

Name and Address of Registrant (include ZIP Code):

Sabre Oxidation Technologies2642 Marco AvenueOdessa, TX 79762

•Note: Changes in labeling differing in substance from that accepted in connection with this registration must be submitted toiand accepted by theRegistration Division prior to use of the label in commerce. In any correspondence on this product always refer to the above EPA registration '.number. . ^;.-.-. _ / . . • " . : . . . . • . . . • • . . • , . ' » • • . , . • / : ' . . ....

On the basis of information furnished by the registrant, the above named pesticide is hereby registered/reregistered under the Federal Insecticide,Fungicide and Rodenticide Act. Registration is in no way to be construed as an endorsement or recommendation of this product by the Agency. Inorder to protect health and the environment, the Administrator, on his motion, may at any time suspend or cancel the registration of a pesticide inaccordance with the Act. The acceptance of any name in connection with the registration of a product under this Act is not to be construed as givingthe registrant a right to exclusive use of the name or to its use if it has been covered by others.

The application referred to above, submitted under the Federal Insecticide, Fungicide andRodenticide Act, as amended is acceptable under FIFRA sec. 3(c)(7)(B), provided that you:

1. Submit and/or cite all data required for registration/reregistration/registration review ofyour product when the Agency requires all registrants of similar products to submit suchdata.

2. A one year study is required to satisfy the storage and stability and corrosioncharacteristics requirements (Guidelines 830.6317 and 830.6320). You have 18 monthsfrom the date of registration to provide these data.

A stamped copy of your labeling is enclosed for your records. This labeling supersedes allpreviously accepted labeling. The next label printing of this product must use this labeling unlesssubsequent changes have been approved. You must submit one (1) copy of the final printed labelingbefore you release the product for shipment with the new labeling. In accordance with 40 CFR152.130(c), you may distribute or sell this product under the previously approved labeling for 18 monthsfrom the date of this letter. After 18 months, you may only distribute or sell this product if it bears thisnew revised labeling or subsequently approved labeling. "To distribute or sell" is defined under FIFRAsection 2(gg) and it's implementing regulation at 40 CFR 152.3.

Signature of Approvi icial:

Demsbn /FullerProduct Manager Team 32Regulatory Management BranchAntimicrobials Division (751 OP)

Date:

J A N - 2 8

EPA Form 8570-

For use only by:

• Federal On-Scene Coordinators (FOSCs) and contractors and other trainedfederal/state/local response personnel under the FOSC's supervision;

• Trained U.S. Military personnel and contractors under their supervision;• Persons who, within the preceding 24 months, have been trained and

determined to be competent by the registrant (or its contractor) followingcompletion of the required training.

Under the terms and conditions of this product's registration, this product mayonly be sold or distributed by the registrant directly to the persons identified

above.

DIKLOR ™G Chlorine Dioxide Sterilant Precursor

SPORICIDAL DECONTAMINANT for INACTIVATION of Bac///us anthracis SPORES onPRECLEANED, HARD, NON-POROUS and POROUS SURFACES

DIKLOR ™G Chlorine Dioxide Sterilant Precursor is a sporicidal decontaminant that inactivates

Bacillus anthracis spores on precleaned, hard, nonporous and porous surfaces at certain sites when

used in accordance with all precautions and directions specified on this label and in the attached DIKLOR

™G Chlorine Dioxide Sterilant Precursor Fumigation Manual(Fumigation manual).

ACTIVE INGREDIENT:Sodium ChloriteOTHER INGREDIENTS:—

25.0%75.0%

TOTAL 100.0%

KEEP OUT OF REACH OF CHILDREN

DANGER

SEE (SIDE) (BACK) PANEL FOR ADDITIONAL

PRECAUTIONARY STATEMENTS AND DIRECTIONS FOR USE

EPA Reg. No. 73139-3EPA Est. No.

Sabre Oxidation Technologies2642 Marco AvenueOdessa, TX 79762Emergency Phone Number1-800-222-1222

.aCJCKPTE

FIRST AID

IF IN EYES

IF ON SKIN ORCLOTHING

IF SWALLOWED

Hold eye open and rinse slowly and gently with water for 15-20minutes. Remove contact lenses, if present, after the first 5 minutes,and then continue rinsing. Call a poison control center or physician fortreatment advice.

Take off contaminated clothing. Rinse skin immediately with plenty ofwater for 15-20 minutes. Call a poison control center or physician fortreatment advice.

Have person sip a glass of water if able to swallow. Do not inducevomiting unless told to by a poison control center or doctor. Do not giveanything by mouth to an unconscious person. Call a poison controlcenter or doctor immediately for treatment advice.

NOTE TO PHYSICIAN: Probably mucosal damage may contraindicate the use of gastric lavage.Have the product container or label with you when calling a poison control center or going fortreatment.

FOR EMERGENCY MEDICAL INFORMATION CALL TOLL FREE: 1-800-222-1222

PRECAUTIONARY STATEMENTS

HAZARDS TO HUMANS AND DOMESTIC ANIMALS

DANGER. Corrosive. Causes irreversible eye damage and skin burns. May be fatal if swallowed.Irritating to nose and throat. Do not breathe dust or vapors. Do not get in eyes, on skin or clothing. Do nothandle with bare hands. Wear protective eyewear (goggles or face shield), clothing and rubber gloveswhen handling. Wash thoroughly with soap and water after handling and before eating, drinking, chewinggum, using tobacco or using the toilet. Remove contaminated clothing and wash clothing before reuse.Other chemical may be co-located for this process, refer to fumigation manual and respective MaterialSafety Data Sheet for chemical specific details.

PPE REQUIRED FOR PROTECTION FROM BACILLUS ANTHRACIS SPORES

When applying the product to areas contaminated with Bacillus anthracis spores, wear the personalprotective equipment (PPE) described in this product's Fumigation Manual, the Fumigation ManagementPlan, or the Remediation Action Plan or equivalent plan.

ENVIRONMENTAL HAZARDSThis pesticide is toxic to fish and aquatic organisms. Do not discharge effluent containing this product intolakes, streams, ponds, estuaries, oceans or other waters unless in accordance with the requirements of aNational Pollutant Discharge Elimination System (NPDES) permit and the permitting authority has beennotified in writing prior to discharge. Do not discharge effluent containing this product to sewer systemswithout previously notifying the local sewage treatment plant authority. For guidance contact your StateWater Board or Regional Office of the EPA.

PHYSICAL OR CHEMICAL HAZARDSDry DIKLOR G is a strong oxidizing agent. Only mix into or dilute with water or non-oxidizablematerials. Mixing with acids or other chemicals may start a chemical reaction with the generation of heatliberation of a hazardous gas (chlorine dioxide), and possible fire or explosion. Do not contaminate withgarbage, dirt, organic matter, household products, chemicals, soap products, paint products, solvents,acids, vinegar, beverages, oils, pine oil, dirty rags or any other foreign matter. Contact with acids mayrelease toxic gas. Use only clean, dry utensils when handling.

EMERGENCY HANDLINGIn case of contamination or decomposition, do not reseal container, if possible, isolate container in anopen and well-ventilated area. Flood with large volumes of water. If fire occurs, extinguish fire byapplying large volumes of water. Cool any unopened drums near the fire by spraying with water.

STORAGE AND DISPOSALDo not contaminate water, food or feed by storage or disposal.STORAGE: Keep product dry in tightly closed container when not in use. Do not drop, roll or skid drum.Keep upright. Always replace cover. Store this product in a cool, dry area away from direct sunlight andheat to avoid deterioration. In case of spill, flood area with large quantities of water. Do not reuse emptycontainer.

PESTICIDE DISPOSAL: Pesticide wastes are acutely hazardous. Improper disposal of excess pesticideor rinsate is a violation of Federal Law. If these wastes cannot be disposed of by use according to labelinstructions, contact your State Pesticide or Environmental Control Agency, or the Hazardous Wasterepresentative at the nearest EPA Regional Office for guidance.

CONTAINER HANDLING:Non-refillable container. Do not reuse or refill this container. Triple rinse container (or equivalent)promptly after emptying. Offer for reconditioning, if appropriate. Triple rinse as follows: Empty theremaining contents into application equipment or a mix tank. Fill the container 1/4 full with water. Replaceand tighten closures. Tip container on its side and roll it back and forth, ensuring at least one completerevolution, for 30 seconds. Stand the container on its end and tip it back and forth several times. Turn thecontainer over onto its other end and tip it back and forth several times. Empty the rinsate into applicationequipment or a mix tank, or store rinsate for later use or disposal. Repeat this procedure two more times.Then offer for recycling or reconditioning, or puncture and dispose of in a sanitary landfill, or incineration,or if allowed by state and local authorities, by burning. If burned, stay out of smoke.

DIRECTIONS FOR USE

It is a violation of Federal Law to use this product in a manner inconsistent with its labeling.

See the accompanying DIKLOR G Chlorine Dioxide Sterilant Precursor Fumigation manual for thisproduct for complete use directions and safety precautions for inactivating Bacillus anthracis (anthrax)spores on porous and nonporous surfaces. The Fumigation manual contains fumigation specificchemical requirements and specifications in Section III, part D. Fumigation dosage concentration andtime are in Section III, part N. This product will be used to create a chlorine dioxide solution at aconcentration level of approximately 0.1 -0.3 % through the controlled reaction of hydrochloric acid (15percent), sodium hypochlorite (10 to 12 %), and sodium chlorite (%), or a prescribed on label. During thefumigation, a minimum temperature of 70° F, minimum Rh of 70 percent, and either (a) a minimum CI02

concentration of 500 parts per million by volume (ppmv) or (b) a minimum CI02 concentration of 3,000parts per million by volume (ppmv) must be achieved. The minimum CT clock value of at least 9,000ppmv must be conducted at all monitoring locations throughout the duration of either 12 hours or 3 hoursfumigation process.

i/fFor use only by:

« Federal On-Scene Coordinators (FOSC) and contractors and other trainedfederal/state/local response personnel under the FOSC's supervision;

o Trained U.S. Military personnel and contractors under their supervision;° Persons who, within the preceding 24 months, have been trained and determined

to be competent by the registrant (or its contractor) following completion of therequired training.

Under the terms and conditions of this product's registration, this product may only besold or distributed by the registrant directly to the persons identified above.

DIKLOR ™G Chlorine Dioxide Sterilant Precursor -Fumigation Manual

Sabre Oxidation Technologies2642 Marco AvenueOdessa, TX 79762

Emergency Phone Number1-800-222-1222

SPORICIDAL DECONTAMINANT for INACTTVATION of Bacillus anthracis SPORES onPRECLEANED, HARD, NON-POROUS and POROUS SURFACES

DIKLOR ™G Chlorine Dioxide Sterilant Precursor is a sporicidal decontaminant thatinactivates Bacillus anthracis spores on precleaned, hard, nonporous and porous surfaces atcertain sites when used in accordance with all precautions and directions specified on the labeland in this Fumigation Manual.

ACTIVE INGREDIENT:Sodium Chlorite 25.0%OTHER INGREDIENTS: 75.0%

TOTAL 100.0%

KEEP OUT OF REACH OF CHILDRENDANGER

SEE (SIDE) (BACK) PANEL FOR ADDITIONALPRECAUTIONARY STATEMENTS AND DIRECTIONS FOR USE

EPA Reg. No. 73139-3EPA Est. No.

Sabre Oxidation Technologies2642 Marco AvenueOdessa, TX 79762Emergency Phone Number

TABLE OF CONTENTS

I. GENERAL APPROACH TO FUMIGATION AND REMEDIATION 3

II. PERSONAL PROTECTIVE EQUIPMENT (PPE) REQUIREMENTS 3

A. Respirator Requirements 3

B. Other Protective Equipment 3

C. PPE Required for Protection from Bacillus Anthracis Spores 4

III. DIRECTIONS FOR USE 4

A. Site Preparation..... 4

B. Building Containment 4

C. Negative Air Pressure and Emission Control 4

D. Chlorine Dioxide Generation 5

E. Chlorine Dioxide Distribution 5

F. Chlorine Dioxide Removal 5

G. Temperature and Rh Control 6

H. Chemical Storage 6

I. Dehumidification 6

J. Process Wastewater 6

K. Ancillary Equipment 7

L. Equipment Testing 7

M. Fumigation Operation Sequencing 8

N. Operational Objectives 8

O. Relative Humidity Monitoring : 9

P. Temperature Monitoring 9

Q. Chlorine Dioxide Monitoring : ..: ; 9

R. CT Clock Monitoring '. 9

S. Use Precautions '. 10

T. Worker Safety .'..'...:. 10

U. Public Safety 1.1

V. Fire Response 12

W. Chemical Spill Response 13

X. Building C1O2 Leak Detection and Repair 14

Y. Adjustment of Operational Parameters 14

Z. Termination of Fumigation Process ; 15

AA. Post Fumigation Repair and Cleaning 15

I. GENERAL APPROACH TO FUMIGATION AND REMEDIATION

The objective of chlorine dioxide (C1C>2) fumigation is to effectively decontaminate buildings and contentscontaminated or potentially contaminated with Bacillus anthracis spores on pre-cleaned, hard, porous and non-porous surfaces under operating conditions that protect site workers, the surrounding community and theenvironment. .

Each fumigated building or subpart thereof must be properly tented or sealed and subjected to negative pressureby extraction of building air though negative air units (NAUs). The C1O2 gas in extracted air is removed bymeans of an emission control system containing activated carbon cells. Specified temperature and relativehumidity (Rh) conditions are to be achieved within the treatment zone prior to the introduction of C102 gas.During fumigation, operational parameters are monitored at an appropriate number of co-located temperature, Rh,and C1O2 gas sampling points. At the end of the specified time period for fumigation, the addition of C1O2 gas isterminated and natural decay of the gas within the building begins. Where necessary, the decay process isaccelerated by the addition of alkaline sodium sulflte, hydrogen peroxide, or erythobic acid solution to the processliquid loop. Decay of C1O2 gas in the building decay continues until such time that C1O2 concentration levels atall monitoring points have fallen below the Occupational Safety and Health Administration (OSHA) eight-hourtime-weighted average (TWA) permissible'exposure level (PEL) of 0.1 parts per million by volume (ppmv), atwhich time the building may be re-entered by fumigation personnel.

The user of this product shall develop a site-specific Fumigation Management Plan (or Remediation Action Planor equivalent) that follows these label instructions and takes into account site-specific information such as the sizeof the structure, materials of construction, contents, conditions, surrounding community particulars, as well asbiological efficacy plan that may include biological indicators, and environmental sampling, etc.

II. PERSONAL PROTECTIVE EQUIPMENT (PPE) REQUIREMENTS

A. Respirator Requirements

When a respirator is required for use with this product:• The respirator must be fit tested and fit checked using a program that conforms with OSHA's

requirements (see 29 CFR Part 1910.134)• The respirator user must be trained using a program that conforms with OSHA's requirements (see 29

CFR Part 1910.134)• The respirator user must be examined by a qualified medical practitioner to ensure the physical ability

to safely wear the style of respirator to be worn.

• The respirator must be maintained according to a program that conforms with OSHA's requirements(see 29 CFR Part 1910.134)

B. Other Protective Equipment

• Protective clothing—long sleeve shirt, long pants, shoes plus socks• Gloves—specify appropriate type• Protective eyewear or face shield

C. PPE Required for Protection from Bacillus Anthrads Spores

When entering areas contaminated with Bacillus anthracis spores, wear the personal protectiveequipment (PPE) described in this product's Fumigation Manual, the Fumigation Management Plan, orthe Remediation Action Plan or equivalent plan.

HI. DIRECTIONS FOR USE

It is a violation of federal law to use this product in a manner inconsistent with its labeling.

A. Site Preparation

To the extent feasible, remove debris, non-reusable items and water-soaked materials. Eliminate sources ofmoisture ingress (e.g., roof or window leaks, damaged plumbing, etc.) that may contribute to water damage and/ormold growth. Open enclosed spaces (e.g., closets, drawers, cabinets, etc.) to allow maximum exposure to the C1O2

gas during fumigation.

B. Building Containment

Tent (encapsulate) the building undergoing fumigation completely with a material demonstrated to be imperviousto C1O2 gas, or effectively seal the building through utilization of sealing materials such as tape, caulking, etc. in .all external cracks, crevices, or building openings, through which C1O2 might escape during fumigation.

C. Negative Air Pressure and Emission Control

For Structures of up to 17.000.000 cubic feetContain C1O2 gas in the building through use of a negative air pressure system designed to maintain a slightnegative pressure on the internal walls and ceiling of the building during fumigation operations. Achieve negativepressure by removing building air through two negative air units (NAUs). Locate the NAUs on opposite sides ofthe building where possible. The systems should be redundant in that each NAU should maintain a negativepressure on the building during times when the second NAU is shut down.

Monitor negative pressure through use of a pressure differential monitor (e.g., MAGNEHELIC® Gauge) installedon each NAU system. Conduct a negative air balance test before fumigation to demonstrate the ability of eachNAU system to independently maintain a negative pressure on the building. Achieve a target negative pressurelevel during fumigation of-0.005 inches of water column or greater.

Air being removed from the building during fumigation to create negative pressure will contain residual C1O2 gas.A treatment train is necessary to remove C1O2 prior to discharging the extracted air to the surroundingenvironment. Provide each NAU with a gas scrubbing treatment train that consists of: (1) an induced draft fan;(2) vapor phase carbon cell; or a wet reducing scrubber in series with a vapor phase carbon cell; and (3) a meansto monitor airflow, pressure differential and gas emission levels.

During fumigation operations, monitor the treated building air exiting the carbon cells to identify potential"breakthrough" of C1O2 gas, which is indicative of exhaustion of the carbon cell media. Monitor potentialbreakthrough by placement of an extractive C1O2 gas sample point at both the inlet and outlet to the scrubbertreatment train. Collect samples from the outlet sample port on a continuous basis.

Pause the fumigation process immediately should breakthrough be observed until the cause of breakthrough isascertained and corrective measures are implemented as necessary. Utilize corrective measures.including one ormore of the following, depending upon the situation: (1) reduce the amount of extraction air coming into thecarbon cell; (2) shut the affected NAU down; (3) switch all air removal requirements to the unaffected NAU; (4)terminate any further C1O2 gas additions to the building; and/or (5) convert the gas emitters to scrubbers toexpedite removal of residual C1O2 from the building.

Provide standby electrical generation power to provide power to critical fumigation systems (including the NAUs)should utility power to a fumigation site be interrupted at any time.

D. Chlorine Dioxide Generation

Generate C1O2 solution in a Sabre Companies LLC (Sabre) mobile C1O2 generation system .that produces C1O2

solution at a concentration level of approximately 1,000 - 4,000 ppm percent through the controlled reaction ofhydrochloric acid (15 percent), sodium hypochlorite (10 to 12 percent) and sodium chlorite (25 percent,- DiKIor GSodium Chlorite Solution, USEPA Registration Number 73139-3) or as prescribed generation method on thelabel.

E. Chlorine Dioxide Distribution

Pump the liquid C1O2 solution from the generator to gas "emitter(s)" strategically located around or inside thebuilding. The emitter(s) remove C1O2 gas from the C1O2 solution into the air stream flowing from the building,through the emitter(s) and back into the building. Allow depleted C1O2 solution to flow back to the generator in aflow loop where it can be "recharged" to its initial concentration level and used again. Continue adding C1O2 gasto the building until the target concentration is achieved and/or maintained in the desired range.

Locate the C1O2 emitter(s) based on building configuration and location of existing Air Handler Units (AHUs).Use the building air distribution ductwork and diffuser system, as necessary, to distribute gas throughout thebuilding treatment area. Design the number of emitters in sufficient quantity to deliver the desired concentrationof CIO2 gas to the entire structure undergoing fumigation. Use supplemental mass transfer fans where necessary inthe building to assist in mixing and dispersion of the gas. .

F. Chlorine Dioxide Removal

At the conclusion of fumigation, allow residual C1C>2 gas remaining in the building to decay naturally;alternatively, if quicker removal of C1O2 is desired, convert the gas emitters into active gas scrubbers. Conversionof the C102 gas emitters into ClO2gas scrubbers is accomplished by adding an alkaline sodium sulfite solution, analkaline peroxide solution or an alkaline Erythorbic acid solution to the liquid C1O2 solution process flow loop.Circulate this solution to the emitters so that C1O2 gas is removed from the building when air is drawn through theemitters.

G. Temperature and Rh Control

Bring the building to a minimum temperature of 70° Fahrenheit (F) for at least one hour at all temperaturemonitoring points before introducing C1O2 gas into the building. Control temperature through use of the building'sexisting heating, ventilation and air conditioning (HVAC) system or through use of portable heat generation orcooling devices. Operate building AHUs in full recirculation mode with no outside fresh air intake to help achievethe desired temperature level before fumigation.

Bring the building to a minimum Rh value of 70 percent for at least one hour at all Rh monitoring points beforeintroducing C1O2 gas into the building. If necessary to achieve and maintain the Rh level above 70 percent, utilizethe emitters as humidifiers by controlling the temperature of water in the circulation loop and adjusting thattemperature through use of steam coils, or cooling the water through a shell and tube heat exchanger. Make everyreasonable effort to limit the development of a condensing atmosphere within the building during fumigation.

H. Chemical Storage

Store precursor chemicals in 55-gallon drums, 275-gallon totes or portable storage tanks. The quantity isdependent on the size of-the building being fumigated. Make provisions for storage of the three C1O2 precursorchemicals and neutralization chemicals (e.g., 25 percent sodium hydroxide, ,36 percent sodium bisulfite^ 50percent hydrogen peroxide, or Erythorbic acid; note: type and quantity dependent on active scrubbing solutionmedia chosen). Store all precursor and neutralization chemicals within secondary containment areas using propersegregation principles to prevent accidental mixing of reactive materials (e.g., store hydrochloric acid within aseparate containment basin away from sodium chlorite and sodium hypochlorite).

I. Dehumidification

Dehumidify the building promptly after completion of C1O2 gas removal to lower the relative humidity level ofbuilding air to at least 60% to facilitate drying of internal building surfaces to prevent growth of mold and mildewpost fumigation. Confirm first that C1O2 levels have fallen below the OSHA TWA PEL standard of 0.1 ppmv atall monitoring locations within the building. Utilize the fumigated building's existing HVAC system to facilitatedehumidification where possible.

Continue the dehumidification process until such time that the moisture content of various types of buildingmaterials such as wood, drywall and masonry reach desired levels. Use a Moisture Encounter Meter whereappropriate to measure the moisture content at various locations inside the building to confirm the effectiveness of •the dehumidification process.

J. Process Wastewater

Store wastewater generated by the fumigation process in a dedicated on-site storage tank. Collect and analyzerepresentative samples of the wastewater for purposes of waste profiling. If the wastewater is determined to benon-hazardous, dispose of into the sanitary sewer system if allowed by the local publicly owned treatment works.Otherwise, send off-site to a permitted, non-hazardous wastewater treatment facility.

K. Ancillary Equipment

Provide standby electrical generation power to provide power to critical fumigation systems should utility powerto a fumigation site be interrupted at any time.

L Equipment Testing

Test all key fumigation system components as they are installed to ensure that all subsystems will operate asdesigned.

Before commencing the fumigation, conduct a low-level "pulse" test in which all subsystems are simultaneouslychallenged as if it were the actual fumigation, with the exception that significantly lower C1O? concentrationlevels are used (i.e., 200 to 500 ppmv) than those used during the actual fumigation process and Cl(>2 is introducedinto the building for a much shorter duration (i.e., 15-30 minutes). Design and conduct the test such that allelements that support the fumigation are proven functional, operational and effective.

During the low-level pulse test, bring environmental conditions inside the building to target levels and verify thatall equipment is operating and functioning properly. Also verify that data collection devices and chemical fluidand gas sampling operations are functioning as designed. Finally, assess the exterior of the building with handheldC1O2 monitors to make sure there are no significant gas leaks.

M. Fumigation Operation Sequencing

Perform fumigation activities in the following operational sequence to ensure safety and efficacy of the process.

TaskNumber

1234

. 5 .67 '8910111213141516171819202122232425262728293031

Task Description

Verify spill containment supplies are in placeVerify necessary chemical inventory is in placeVerify acceptable meteorological conditions existConduct pre-fumigation safety meetingVerify Emergency Response Team is in placeVerify Operations Team is in placeVerify, building AHUs are operatingVerify Mass Transfer mixing fans are operating (when needed)Initiate NAU operationAchieve desired building negative pressures

•Initiate liquid flow loop water circulationInitiate emitter blower operationAchieve desired temperature and Rh levelsTurn off all lights in buildingConfirm all personnel are out of buildingInitiate C1O2 generationInitiate C1O2 concentration "ramp-up"Initiate internal and external C1O2 gas samplingAchieve minimum desired C1C>2 concentration to start CT clockMaintain C1O2 concentration above target levelAchieve desired CT clock value at all monitoring locationsTerminate C1O2 generationInitiate active C1C>2 scrubbing (when needed)Terminate scrubbing operationsShut-down emitters and liquid process loopTerminate gas sampling when C1O2 < 0.1 ppmv

Initiate building dehumidificationConduct building inspection entryTurn on lights in buildingTerminate building dehumidificationTurn off AHUs, fans and N AUs

N. Operational Objectives

Achieve a minimum temperature of 70° F, minimum Rh of 70 percent, and either (a) a minimum C1O2

concentration of 500 parts per million by volume (ppmv) or (b) a minimum C1O2 concentration of 3,000 parts permillion by volume (ppmv) at all monitoring locations to start the concentration by time (CT) building exposureclock.

Conduct fumigation with a minimum duration of either (a) twelve (12) hours or (b) three (3) hours that achieves aminimum CT Clock value of at least 9,000 ppmv-hours at all monitoring locations.

0. Relative Humidity Monitoring

Monitor Rh at an appropriate number of co-located building locations through use of HOBO® Model U12-011TEMP/RH Data Loggers or equivalent. The instrument has a measuring range of 5 to 95 percent with an accuracyof ± 2.5 percent. Take measurements at 5-minute intervals during the conditioning, fumigation and aerationphases of the process. Obtain a local readout of Rh readings by connecting the data loggers to a personal computer(PC) via USB, Cat 5 data cable or fiber optic cable from the various monitoring locations. Log data in the monitorduring fumigation and download for manipulation following fumigation.

P. Temperature Monitoring

Monitor temperature at an appropriate number of co-located building locations through use of HOBO® ModelU12-011 TEMP/RH Data Loggers. The instrument has a measuring range of -4 to 158° F with an accuracy of ±0.63° F. Take measurements at 5-minute intervals during the conditioning, fumigation and aeration phases of theprocess. Obtain a local readout of temperature readings by connecting the data loggers to a PC via USB Cat 5data cable or fiber optic cable from the various monitoring locations. Log data in the monitor during fumigationand download for manipulation following fumigation.

Q. Chlorine Dioxide Monitoring

Monitor C1O2 concentration levels by means of a composite sample collection system constructed of 3/8-in insidediameter high-density polyethylene (HDPE) tubing. HOPE tubing has been shown to be non-reactive with C1O2.Run the tubing from an appropriate number of co-located monitoring locations inside the building to a centralsampling manifold located outside the building. Have knowledgeable air-sampling technicians collect samplesand deliver them to an on-site gas laboratory for analysis. Place a vacuum pump on the downstream side of thesampling manifold to move air through the system and return it to the building on a continuous basis such that thesamples represent existing conditions within the building at the time they are taken.

Collect samples from the sampling manifold via impingement of two liters'of air at a flow rate of 1.0 liter perminute through 15 milliliters of a strongly buffered pH 7 potassium iodide solution (modified OSHA MethodID126SGX). Once collected, analyze samples via amperometric titration, using a 0.1 normal sodium thiosulfatesolution as the titrant (modified American Water Works Association Method 4500-C1O2-E and modified 2-stepversion of same).

During C1O2 ramp-up, collect samples at a select number of monitoring locations every 15 minutes until theminimum CT Clock start value is demonstrated at these locations. Once the' minimum CT Clock start value hasbeen established, collect samples at all monitoring locations every 30 minutes for the remainder of the fumigation.It is possible that additional samples may be required outside of the normal rotation sequence of one sample perhalf-hour. Reasons that could trigger increased sampling include abnormally low or high C1O2 concentrationreadings, mechanical problems with the sampling pump or impingers, condensate in the sampling tubing, etc.Commence the use of an increased sampling frequency when necessary due to special circumstances and continueuntil the situation that initiated the problem is corrected.

R. CT Clock Monitoring

Start the CT clock when the desired minimum C1O2 concentration level (either 500 or 3,000 ppm) is reached at allselected monitoring locations. Once started, accumulate CT exposure credit so long as the C1O2 concentrationlevel remains above the minimum established criteria value, as do temperature and Rh readings. Continue thefumigation until all monitoring locations have achieved a 9,000 ppmv-hour minimum CT clock value. Placeaccumulated CT clock values on hold if the established minimum Rh, temperature and CIO2 concentration values

are not maintained. Restart the CT clock during the next sampling period during which all three process variablesare found to be in compliance with the prescribed minimum values.

S. Use Precautions

Conduct fumigation operations in a manner that protects both workers and members of the general public fromexposure to fumigation process chemicals through implementation of specifically designed safety measures.

T. Worker Safety

Site-Specific Health and Safety Plan

Develop a site-specific Health and Safety Plan (HASP) to establish safe working and operating conditions for bothfumigation preparation activities and fumigation operations. Prepare the HASP in accordance with applicableOSHA guidelines and regulations.

Health and Safety Training

Establish minimum health and safety training requirements for all personnel involved in fumigation operations.Do not allow workers to participate in, or supervise field activities until they have been trained to a level requiredby their,job function and responsibility. Cover appropriate elements during initial training including: (1) names ofpersonnel and alternates responsible for site safety and health; (2) safety, health and other hazards present on site;(3) proper use, care and maintenance of PPE; (4) work practices by which the worker can minimize risks fromhazards; (5) safe use of engineering controls and equipment on site; (6) medical surveillance requirements,including recognition of symptoms and signs which might indicate over exposure to hazards; and (7) contents ofthe site HASP.

In addition to initial training, provide Hazard Communication (HAZCOM) and Respiratory Protection training. InHAZCOM training, provide information on the possible types of biological or chemical agent contaminationpresent within a facility, as well as the chemical substances stored and generated on-site, including physicalproperties, fire and explosion data, reactivity data, health hazard data, emergency and first aid procedures, spilland leak procedures, etc. In Respiratory Protection training, provide information about the proper selection,fitting, use, care and maintenance of respirators, with an emphasis on specific respirators worn if responding to anemergency involving either a chemical release or a fire. Provide basic First Aid and CPR training to all personnelwho might be involved in a response to a medical emergency on-site.

Provide an orientation briefing to individuals who are on-site for short periods of time performing limited tasks aseither visitors or contractors, including an overview of the site-specific HASP and a discussion of the facilitylayout. Also make these individuals aware of evacuation notification procedures and alert them to the pre-determined emergency response Rally Points or places of safe refuge where they should report in the event of anemergency.

Post-Fumigation Building Re-Entry Requirements

Establish a post-fumigation building re-entry requirement that prohibits workers from re-entering the building inOSHA Level D protective equipment until such time that it has been demonstrated that the concentration of C1O2

at all monitoring points has fallen to a level below the applicable OSHA TWA PEL standard of 0.1 ppmv.

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U. Public Safety

Coordination with Local Authorities

Coordinate in advance with local agencies responsible for providing emergency response services regarding thefumigation process and make them aware of facility information, potential chemical hazards and on-site responseprocedures so they will be prepared to effectively respond or assist should an emergency event occur. Whereappropriate, conduct an on-site orientation session to familiarize authorities with the site as well as the potentialemergency events and hazards associated with ori-site chemical storage and C1C>2 generation events.

Site Emergency Planning

Conduct meetings on-site periodically to discuss project roles and responsibilities, site communication procedures,hazardous materials storage issues and potential hazards. The goal of these meetings should be to gain consensuswith regard to roles and responsibilities during potential emergency events.

Site Security

Establish site security measures to prevent unauthorized entry to the site and secure the site perimeter during on-going fumigation preparation activities. Include site entry control procedures, personnel responsibilities, facilitylighting requirements and emergency communication procedures.

Specialized Training

Provide specialized training to prepare site personnel to respond to a variety of potential emergency eventscenarios that might occur during fumigation preparation activities or during the fumigation itself including a fireinside or outside the building, chemical spill and/or a release of a significant amount of the fumigant to theatmosphere during fumigation.

Emergency Response Supplies and PPE >

Stage appropriate spill response supplies in location suitable for cleanup of hazardous materials being stored on-site in close proximity to the stored materials. Also stage a variety of PPE, including Self-Contained BreathingApparatus, at appropriate locations for use in an emergency response to a potential hazardous material release.

Site Communications

.Assign two-way radios to key personnel at the site. Two-way radios facilitate effective communication among allparties at the worksite and allow for careful monitoring of work tasks by individuals responsible for initiating andperforming emergency response activities. Use separate channels for work being performed inside and outside thebuilding so that individuals monitoring the work can effectively monitor tasks being performed in both locationssimultaneously.

Surface and Ground Water Protection

Protect surface and ground water supplies by containing any chemical release that might occur within a secondarycontainment area and respond with absorbents and neutralizing agents stored on-site. Place impervious spill mats

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in close proximity to storm drains in the vicinity of chemical storage areas where necessary. Deploy these matsimmediately to cover drainage catch basins in the event of a chemical release from a primary storage vessel.

Site Evacuation Contingency Plan

Develop specific procedures to respond to a potential emergency response scenarios that might occur duringfumigation preparation operations or .the fumigation itself. Identify a Site Safety and Health Officer (SSHO) whois responsible for determining when on-site personnel should "Shelter-In-Place" or evacuate the site should anemergency evacuation of the site be contemplated.

V. Fire Response

Place fire extinguishers throughout the site, both inside and outside the building, for use in fighting an incipient-stage fire. Also, activate existing operational building fire suppression systems in the event of a fire inside thebuilding.

In the event that a fire is detected either inside or outside the building, implement a series of predeterminedresponse measures including the following:

• The individual who identifies the fire immediately alerts their Supervisor, the SSHO and theEmergency Response Coordinator (ERC) for the site.

• If the individual who identified the existence of the fire can immediately extinguish it with a localfire extinguisher without endangering themselves or others, they extinguish the fire while the ERCis assembling the on-site Emergency Response Team (ERT).

• The on-site ERT dons proper PPE and initiates emergency response .activities. The ERT isprovided with PPE as warranted by the nature of the fire

• Potentially affected electrical systems are deactivated as soon as possible if appropriate to preventa spread of the fire.

• After donning appropriate PPE, the source and nature of the fire are investigated. If the fire isdetermined to be in its incipient stage, the ERT attempts to extinguish the fire. If a fire eitherinside or outside the building is determined to be beyond the incipient stage, the SSHO or ERCimmediately requests the assistance of external emergency fire response authorities.

• The SSHO notifies all site workers to cease their activities, shutdown all process equipment andreport to a designated location so that a "headcount" may be taken to account for all personnel.

• The SSHO determines if a site evacuation is necessary. If instructed to evacuate, personnelproceed to one of the designated Rally Points or to an off-site place of safe refuge.

• If the fire emergency also involves a release of hazardous materials, the release is addressed inaccordance with the response measures outlined in Section 4.2.3 of this Plan.

• If necessary, based on the size and scope of the fire, the SSHO notifies appropriate externalauthorities and provides them with appropriate information about the fire.

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W. Chemical Spill Response

Locate all storage vessels within secondary containment areas. Store incompatible materials within separatesecondary containments. Place impervious spill mats near all storm water catch basins in the vicinity of chemicalstorage areas where necessary to prevent inadvertent discharge of chemicals through the storm drain sewer systemin the event of a leak or other accidental release.

In the event that a hazardous material leak from a storage vessel or associated piping is detected, implement aseries of predetermined response measures including the following:

• The individual who identified the release immediately alerts their Supervisor, the SSHO and theERC for the site.

• The ERC assembles the 6n-site ERT, who don proper, PPE and initiate response activities. TheERT is provided with PPE as warranted by the nature of the hazardous material release.

• After donning appropriate PPE, the source and nature of the release are investigated and therelease is stopped at its source (if safe to do so). Spill mats are placed over storm drain catchbasins to prevent discharge of spilled material to the storm water drainage system and/or to groundwater where necessary. Any sources of ignition present in the area are also eliminated."

• If any personnel have been affected by the release, they are evacuated from the area of impact assoon as possible and first aid is administered as appropriate. If necessary, external medicalemergency response authorities are summoned.

• Only members of the ERT involved in overseeing or performing emergency operations areallowed within the designated hazard area. If possible, the area is roped or otherwise blocked off.If a release cannot be immediately contained within a containment area, an isolation area isestablished around the spill, using sorbent and neutralizing materials.

• In the event a release breaches onsite secondary containment, the leading edge around the spill iscontained with neutralizing agents and/or absorbents or other appropriate materials. Pumps may beemployed to transfer spilled liquids to on-site waste tanks and for.the removal of any liquid thatmay congregate at low points or depressions on surfaces.

• If the total amount of hazardous material released is less than the equivalent volume of 300gallons, spill response materials and equipment located on-site are utilized to contain and collectthe waste.

• Collected waste material is stored in secure storage containers for future disposal.

• If the amount of hazardous material released is greater than that which can be contained andcollected for disposal by the on-site ERT, arrangements are made with an external contractor torespond to the site with adequate supplies and equipment to perform necessary clean-upoperations.

• The SSHO determines if a site evacuation is necessary. If instructed to evacuate, personnelproceed to one of the designated Rally Points or to an off-she place of safe refuge.

• The SSHO notifies external emergency response authorities if deemed necessary by the size andscope of the release. External emergency response authorities will take appropriate actions ifrequired to safeguard the surrounding community.

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• Following the initial spill response, provisions are made to conduct a full environmentalassessment to delineate impacted areas. Hazardous materials generated from a release are disposedof off-site in accordance with applicable laws and regulations.

X. Building C1O2 Leak Detection and Repair

Perform ambient air monitoring during both the low-level "pulse" test and the actual fumigation to identify leaksof C1O2 gas from the building so that appropriate action may be taken in the event a leak is detected. -Wheneverpossible, repair building leaks immediately using appropriate patching materials.

Dispatch teams of trained employees to the immediate perimeters of the building, and to the rooftop whereappropriate, as soon as C1C>2 liquid begins flowing from the generator to the emitters. Initially assign at least twoteams to building monitoring duties. Each team should consist of at least two individuals, each having hadsufficient previous experience with C1O2 to readily identify its characteristic odor in air.

Equip each monitoring team with a calibrated Industrial Scientific Gas Monitor with a C1O2 sensor capable ofdetecting C1C>2 gas and reporting TWA readings for purposes of comparison with OSHA's eight-hour TWA PELand the American Conference of Governmental Industrial Hygienists (ACGIH) recommended 15-minute TWAShort Term Exposure Limit (STEL). The OSHA PEL for C1O2 is 0.1 ppmv, and the ACGIH STEL is 0.3 ppmv..Because the human olfactory response to C1O2 has been shown through experience to be far more sensitive thanany commercially-available hand-held monitoring technology, the primary objective of using the monitor is notto identify the presence of C1O2 emissions, but rather to make sure that team members are not being exposed toconcentrations of the gas that are in excess of prescribed standards and recommended threshold levels while theyare performing their ambient monitoring and repair assignments. In the event that C1O2 readings above the 0.1ppmv eight-hour OSHA standard or .the 0.3 ppmv 15-minute ACGIH STEL are registered by a monitor duringfumigation, the team identifying the reading should leave the area where the elevated reading was identified anddon appropriate respiratory protection before continuing work in the area. A full-face negative pressure respiratorwith combination P-100 filter/acid gas cartridges should be used for C1O2 concentrations above an applicableexposure standard but less than 5 ppmv. A self-contained breathing apparatus and appropriate skin protectionshould be used in any atmosphere containing more than 5 ppmv of C1O2.

Identify potential sources of C1O2 emissions from the top and sides of the building and immediately perform anyrepairs and/or modifications necessary to eliminate or reduce emissions to the greatest degree possible. Also,communicate monitoring findings to the Project Manager so that operational changes and/or a shutdown offumigation operations can be initiated immediately in the event that a leak cannot be effectively patched in areasonable period of time. When a building leak cannot be quickly and effectively repaired, adjust operationalparameters as necessary to mitigate the leak or terminate the fumigation process to eliminate exposure risk to thesurrounding community.

Y. Adjustment of Operational Parameters

In the event a C102 leak cannot be promptly repaired through use of available patching materials, adjustfumigation operating parameters, either temporarily or for the remaining duration of the fumigation, to preventadditional gas from escaping the building into the surrounding environment.

Increase the NAU fan speed upwards to increase the negative pressure level on the internal walls and ceiling ofthe building and/or decrease the target C1O2 concentration level being applied to the building to lower theconcentration of CIO2 in air escaping through the leak.

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Z. Termination of Fumigation Process

Should it be "determined that a significant C1O2 leak cannot be effectively repaired, nor can the magnitude of theleak be substantially mitigated through adjustment of operational parameters, terminate the fumigation processand-take necessary measures to remove residual gas from the building.

Turn gas emitters into gas scrubbers through the addition of an appropriate neutralizing agent to the liquid ClOiflow loop. Circulate this solution from the generator to the emitters to remove C1O2 from the building as air isdrawn through the emitters.

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AA. Post Fumigation Repair and Cleaning

Remove any remaining debris, non-reusable items and water soaked materials. Replace, repair or clean damagedareas of structure as needed.

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